New York Requests for Production of Documents and Things
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FAQ
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
The following (if applicable) are some grounds for objecting to a request for admission: ? The request is vague or overbroad. ? Attorney-client privilege. ? The request is not relevant to this case.
You can write back to the person making the request and explain why you are objecting. You must have a valid reason to object to giving the other party the documents.
I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...
A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing.
(b) Document Demand: As the name indicates, this is a written demand in which one party demands that the other produce certain documents for inspection and copying. (This device is also referred to as a notice of discovery and inspection). The demand must define the items sought with reasonable particularity.